IR 05000255/1992019

Forwards Insp Rept 50-255/92-19 on 920831-0903.No Violations Noted.Weaknesses Identified

ML18058B118
Person / Time
Site:	Palisades
Issue date:	09/24/1992
From:	Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML18058B119	List: IR 05000255/1992019
References
NUDOCS 9210060157
Download: ML18058B118 (28)

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Docket No. 50-255 Consumers Powe~Company ATTN:

Gerald. B. Slade General Manager Palisades Nuclear Generating Plant 27780 Blue Star Highway C9vert, MI 49043 Gentlemen:

SEP 2 4 199Z This refers to the routine safety inspection conducted by Mr. 'J. Foster and others of this ~ffice on August 31 - September 3, 1992. _The inspection included a review of authorized activities at your Palisades facilit At the conclusion of the inspection, the findings*were discussed with those members of your staff identified in the enclosed r~por Areas examined during the inspection are identified in the report. Within these areas, the insp~ction consisted of a selective examination of proced~res and repr*esentative records, interviews with personnel, and observation of *

activities in progres *

No violations of NRC requirements were identifie_d during the course of this inspectio Howev~r, one exercise weakness was identified during this inspection which will r~quire corrective actio This weakness is summarized in the Appendix to this lette As required by 10 CFR 50, Appendix E (IV.F),.

any w~aknesses that are identified must be correcte In accordance with 10 CFR 2.790 of the Commission's regulations, a ~opy of this letter and the enclosed inspection report will be placed in the NRC Public Document Roo We will gladly discuss any questions you have concerning this inspectio Enclosures

Sincerely, I-

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Cynthia D. Pederson, Chief Reactor Support Programs Branch Appendix - Exercise Weakness Inspection Report No. 50-255/92019(DRSS)

See Attached Distribution R,1(}0 Hlfer;j /27./92 yis

~Markley 9210060157 PDR ADOCK A

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Pederson 920924 05000255 PPR

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Distribution

• cc w/enclosures:

• David P. Hoffman, Vice President Nuclear Operations M~ Drinnelly, Safety and Licensing Director DCD/DCB (RIDS)

OC/LFDCB Resident Inspector, Riii James R. Padgett, Michigan Public

• Service Commission Michigan Depattment of-Public Health Palisades, LPM, NRR SRI, Big Rock Point D. Bement, FEMA, Region V R. Erickson, EPB, NRR

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• SEP 2 1i 1992

APPENDIX Exercise Weaknes~

During the 1992 eme~gency prepa~edness exercise~.the (simul~tor) Control Room staff failed to use Emergency Action Levels to classify plant con,ditions (elevated reactor coolant activity) which warranted an Alert classificatio {Section 6.a)(ltem No. 255/92019-01).

U.S. NUCLEAR REGULATORY COMMISSION REGION II I Report No. 50-255/92019(DRSS)

Docket No. 50-255 Licensee:

Consumers Power Company Pali~ades Nuclear Generating Plan Blue Star Memorial Highway Covert Ml, 49043 Fa~ility Name:

Palisades Nuclear Plant Inspection At:

Palisades Site, Covert, Michigan

. Inspection~Condu:t? A~

September 3, 1992 Inspectors:

J. E. Foster

Team Leader*

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); A. Markley Accompanying Personnel

T. Lonergan Hickey *

Approved By :1

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t Passehl Gamberoni

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J. W. McCormick-Barger, Chief Emergency Preparedness and Non-Power Reactor Section Inspection Summary

. License No. DPR-20 o;,l.2-2/1'2

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. o"ate ;

Inspection on August 31 - September 3, 1992 (Report No. 50-255/92019(DRSS))

Areas Inspected:

Routine, announced inspection of the Palisades emergency preparedness exercise involving review of the exercise scenario (IP 82302},

observations by six NRC representatives of key functions and locations during the exercise (IP 82301}, and follow-up on licensee actions on previously id~ntified items (IP 92701).

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Results:

No violations, defici~ncies or d~viations were identifie The licensee demonstrated a good response to a hypothetical scenario involving a steam generator tube rupture event, equipment failures and a large radiological releas One exercise weakness related to failure to classify one of the initial.events (high reactor coolant activity} as an Alert was identified (section 6.a}. A number ~f communication~ problems were observe This was the first time *t.he licensee had utilized their plant simulator in an exercise, greatly adding ~o realism for the reactor operator.

PDR ADOCK 05000255 G

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\\ *. DETAILS NRC Observers and Areas Observed J. Foster, Control Room~ Technical Support Center (TSC)~ Operations Support Center (OSC), Emergency Operations Facility (EOF)

T. Markley, Control Room, TSC, DSC, EOF T. Lonergan; OSC

E. Hickey,. EOF D. Passehl, Control Room M. Gamberoni, Control Room, TSC Persons Contacted Consumers Power Company

• N. Brot, Emergency Preparedness Coordinator

• J. Brunet, Licensing

• A. Clark, ALARA Program Coordinator

• M. Dawson, Nuclear Instructor II

• D. Donne 1 y, Pl ant Safety and Licensing Di rector

• J. Kuemin, Licensing Administrator

• R. McCabe, Performance-Specialist

• M. Mitchell, GOEP Senior Emergency Planner

• T. Neal, ~p Support Superintendent*

• K~ Osborne, Systems Engine~ring Manager

• K. Penrod, Nucl.ear Operations Analyst

• C. Reavy, Senior HP Technician

• M. Savage, Public Affairs Director

• J. Schepers, Performance Specialist

• G. Slade, Plant General Manager

• J. Warner, Property Protection

• J. Werner, Quality Assurance

• Denotes those attending the NRC exit interview held on September 3, 199 The inspectors also contacted other lic~nsee personnel during the course of the ins~ectio.

Licensee Action on Previously Identified Items (IP 92701) {Closed) Open Item No. 255/90011-01:

During the 1990 annual exercise, the licensee failed to adequately coordinate Operational Support Center/Maintenance Support Center (OSC/MSC) activities at a supervisor or director level. There was no adequate method to identify and track inplant team The layouts of the OSC and MSC were revised so that the. former MSC is essentially a staging area for maintenance and chemistry technicians. A status board was added to the TSC so that the status of inplant teams can be monitore This organizat1on and system of tracking functioned well during the 1992 exercise. This item is close '*..

• • . (Closed) Open Item No. 255/91013-01:

During the 1991 annual exercise, OSC/MSC functions had improved, but were still con~idered inadequate as to the methodology of tracking inplant teams, and setting of team task prioritie As noted above, significant changes were made for the 1992 exercise in terms of facility organization, status boards, and tracking of teams and tasks. in the TS While some improv~ments can still be accomplished, the system functioned well. This item is clo~e (Closed) Open Item No. 255/92005-01:

This item tracks the failure to hold a successful augmentation test.. The licensee addressed this in Deviation Report D-PAL-91-159, and modified augmentation call-in procedure EI Evaluation revealed that much of the problem was related to the call-in systems' (telecomputers)

difficulty in recogQizing positive fesponses (tone dialing is not available.in all areas).

The current procedure calls for one individual to make calls along with the three telecomputer Records reviewed.indicated that the last semi-annual test was considered succe~sful. This item is closed~

Genera 1 This was an announced, daytime exercise of the Palisades Emergency Plan, conducted at the Palisades Nuclear Plan The exercise tested the licensee's and offsite agencies emergency support organizations'

capabilities to respond to a simulated accident scenario resulting in a major release of radioactive effluen The state and local counties participated fully, except for Berrien County, which participated partially (Berrien County participates fully with the Donald C. Cook plant). Attachment 1 describes the Scope and Objectives of the exercise and Attachment 2 describes the exercise scenari General Observations *

The licensee's response was coordinated, orderly and timel If the scenario events had been rea 1, the actions taken by the 1 i censee would *

have been sufficient to mitigate the accident and permit state and local authorities to take appropriate actions to protect the public's healt and safety. Activities by state and local authorities were observed by a team of Federal Emergency Management Agency (FEMA) evaluator FEMA will be issuing* a separate report~

• Specific Observations (IP 82301) Control Room (CR)

This is the first year that the licensee has utilized a plant simulator for Control Room staff use during an exercise.* The use of a simulator greatly enhances the realism of an exercise_

scenario for operators, but also causes some exercise artificialities. Such exercise artificialities incltide loss of dir~ct cont~cts with Control Room staff (the simulator is onsite but distant from the plant) and for full participation exercise such as this, the ability to closely monitor operator actions and prevent actions which would compromise the offsite stenari..

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Pre-exercise briefings were thorough and well conducted.*

Operations personnel appeared to be very knowledgeable of their craf Changes and trends in parameters monitored by active

• systems were readily recognize Use of procedures and technical specifications to evaluate and respond to plant status changes were excellent. Procedure EOP. - 1.0,. "Post Trip Actions" was performed very wel The initial event (high reactor coolant system activity) was not assessed nor classified within fifteen minute Operators properly consulted plant Technical Specifications, and ~ere aware that coolant activity levels placed them in a. 72-hour Limiting Condition for Operation (LCO).

However, th~ Emergency Action Levels (EALs) were not consulted to determine if this event was classifiable as an-emergenc A controller prompted the Alert

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declaration to preserve the offsite scenario timelin The Aler was declared 20 minutes after Primary Coolant System (PCS)

activity exceeded the EAL requirement for the declaration of an Aler This will be tracked as Inspector Followup Item N /92019-01 '.

Communicatioh with state and local go~ernment~ was done promptly after the Alert declaration. There was good use of the Emergency Action checklis Some ambiguous communication occurred during attempts to sample the containment sump and Primary Coolant System (PCS) at 0929 hour0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.534845e-4 months <br /> It ~as not clear that the vartous parties understood whether the sump or the PCS or both were being sample No violations or deviations were ~bserve Technical Support Center (TSC)

The Technical Support Center (TSC) was rapidly activated and assumed responsibility for command and control of the utility response to the accident within goal timeframe In gene~al, the existing facility ~as well utilize With the.

confined space, the existence of small rooms and room dividers allowed separation of groups and minimized distraction The TSC was somewhat crowded and was compact, which contributed to apparent initial confusio At times, noise levels were hig Although the activities in this facility initially appeared to be somewhat confused and lacking focus, periodic management briefings conducted by the Site Emergency Director (SED) provided the requi$ite focu Command and control became eviden Good control by the SED at the tiirectors' briefings was evident throughout the drill. The SED ensured all Directors were present, asked for status from each Director and appropriately solicited suggestions and recommendations for actions such as plant shutdown, operation of atmospheric dumps versus code.safety valves, repair of code safety valves and minimization of release ;...

In the early stages of the scenario, there were good briefings from the various area Directors (i.e. Health Physics, Maintenance)

to their staff following the Directors' meetings with the SE This did not seriously decline during the exercise but it was not as obvious in the later stages, possibly because of saturation of information. - *

The decision to commence an orderly shutdown should have come sooner due to the unidentified source of fuel element failure Although the scenario dealt with mechanical fretting*due to vibration, the cause could easily have been loose parts in the reactor vesse Offsite authorities did not provide a location where the licensee could direct evacuated non-essential site personne The licensee, responded well, evaluating the ~lume pathway and the acceptability of pos~ible relocation centers. This evaluation process di consume some time, possibly delaying other action Emergency Action Level information was continuously reviewe There was a good response to the decline in overall plant conditions and the characterization of this situation as a General Emergency.. The evaluation of emergency classification upgrade from Alert to.General Emergency included good discussion, specifically regarding the basis for ~lasstficatio The communic~tions group had good discussions.with the Emergency Operations Facility (EOF) in preparation for turnover from the TSC to the EO The communications group ensured that the EOF had all the correct t~lephone number *

Acceptance of command and control by the EOF was deliberately delayed until several actions, i~itiated by the TSC, were completed, and this appeared to be a proper decisio When command finally changed from the TSC to the EOF, shift of responsibility was made clear. The SEO called the EOF, made an announcement and asked his Directors if they had turned*

• responsibilities over to their fOF counterpart There was so~e uncertainty between the EOF, the TSC and the Control *Room regarding the status of the code safety valve Otherwise there was excellent, continuous communications between the Control Room and the TS Activation of the Emergency Response Display System (EROS) was unsuccessful, and the cause of the failure was unknow Status of some of the inplant teams dispatched was unclear later in.the drill. For example, the status board showed more than one team dispatched to work on the "R" electrical bu Meteorological information was updated and posted throughout the exercis Downwind sectors were utilized to determine the radius for evacuation (for those sectors).

The board showing plots of p1a~t conditions (i.e. Steam Generator trend) did not appear to be utilized or prominen However, updates from the Control Room via telephone kept the SED and staff infoimed of these critical parameter Overall, the TSC performed well in the areas of accountability, TSC and plant announcements, and communjcations with offsite personne * *

No violations or deviations were observe Operational Support Center COSC)

The OSC was *activated in an efficient and timely mannet and in accordance with Emergency Implementing Procedure EI. Telephones, sound powered telephones and radios were ~xpeditiously placed in service and communication was quickly established with the Control Room, the TSC and offsite monitoring team *

The initial and subsequent routine habitability surveys of ~he OSC were conducted in a timely and thorough ~anner. A radiation survey (frisker) station as well as stations for dose and equipment control were established at the entrance of the OSC within ten minutes following initial announcement of the Aler Atcountability in the OSC was conducted by verbal roll cal Crafts personnel were then quickly relocated to the OSC holding area across the corridor in the locker roo The OSC director provided timely and adequate updates on the

. status of the emergency to the OSC occupant OSC crafts personnel located in the OSC holding area (locker room) heard each update.by means of an intercom system between the OSC proper and the holding area~

Several inplant teams were -Observed from the time of thei~

~election through briefings, team planning, the donning and removal of protective equipment, the selection of primary and/o alternate routes to the work site, and during the conduct of assigned tasks at the work site. The participants in all teams observed demonstrated serious concern for the accomplishment of their assigned tasks and a proficiency in the exercise of good general safety and health physics practice Some instruments did not comply with procedure AD 7.01 in th~t operational checks had not been performed on instruments taken from storag Some instruments were taken from operational use and had operational checks performe Elevated noise lev~ls in the OSC proper appeared to add stress to the conduct of operations, particularly during the briefings and debriefings of OSC team The failure to efficiently use the space which was available.in the OSC, i.e., the space between the

vending machines, res-ulted in crowding and the increase of noise levels in the limited space directly in front of the HP Supervisor's station and the OSC Director's Station and their associated communicators. It was in this area that most of the team briefings and debriefings were conducte A more forceful demand by the OSC Director for maintenance of low noise levels would have reduced the stress during the briefing and debriefing of team OSC per~onnel otganized, dispatched and tracked 29 onsite teams and 2 offsite teams during this exercis As many as 9 teams were committed at one time, although some of the teams consisted of

only one perso All teams were designated by a number on the OSC

• Team Tracking Status Boar In the above case where 9 teams were in the field they were identified' on the OSC status board by team n~mbers 1 through However, when a numbered team completed its assigned task it was remo~ed from the team status board and a subsequently assigned team would be assigned the same numbe Thus during the exercise several teams, each with a different assigned task and composition, could be designated by the same team numbe The use of such a system of team designations could l_ead to confusion in communications in an actual emergenc At one point it was determined that a particular team would be required to use self contained breathing apparatus (SCBAs).

Records of those qualified for the use of SCBAs were not available in the OSC.. An HP player was dispatched to the HP control point to.obtain a printout of those individuals currently qualified for use of the SCBA Due to the simulated contamination between the OSC and the HP Control Point, the HP player was required to dress out in anticontamination clothing, introducing an unnecessary delay into the teams' dispatc Consideration should be given to ensure that printouts of all _such pertinent qualification records

.be included with the initial equipment kits brought from the HP Control Point to the OSC.upon activatio Although the briefings and debriefings observed during thi~

exercise appeared adequate and were documented on '.'form 40"

~essage forms, this information was sometimes crypti The development and use of a single page briefing and debriefing form for the documentation of essential team guidance in briefings and the documentation of team actions taken in debriefings could provide a useful tool and expedite both the briefing and_

debriefing proce~s. The use of stich a form would also ensure that essential guidance would be provided to each tea No violations or deviations we~e obsetve Emergency Operations Facility (EOF)

The Emergency Operations Facility (EOF) was set up and ready to assume Command and Control within one hour of the decision to activate the facility.. The facility was not prestaged in any way and the actual setup, which included plugging in phones, m.oving tables and chairs, and hanging status board~* was performed in an

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efficient manner by the Consumers Power Conference Facility staff.

. A decision to postpooe transfer of command and control from the TSC to*the EOF was made to allow the TSC to complete the -decision and notification process for upgrading to the General Emergenc This postponement caused the actual activation of the EOF to take approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 20 minutes._.. In general, command and control of the event from this facility was very goo The decisipn making processes were also very goo The EOF Director quickly ~stablished com~and of the EOF upon arrival and found out what plant status was and the status of the EOF activatio He maintained cbnt~ol of the facility throughout the exercise, although the Emergency Officer (EO) frequently performed duties delegated by the Directo The EOF Director and the EO performed ~ell.as a tea Between the two, they managed, controlled and directed the EOF. * Information flow between the two was excellent and allowed each.of them th ability to work without too much distractio Adequate updates to the EOF staff were made by the EDF Directo In addition, the EOF Director frequently met with the EOF Team Leaders to obtain status of the various activities going on in the ED Although the EOF is 10 miles distant from the plant, the EOF Director was aware of* potential h~bitability problems (since the EOF was potentially in the rele~se plume).

Dosimetry was issued to the staff and potassium iodide (Kl) was simulated as being given ou The PAR chart in proc~dure El~6.13, attachment 1 needed to be

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revised to uhambiguously state what the criteria wer~ for specifi~

recommendations.. There were sevsral different interpretations of the meaning of "consider evacuation if ther~ are no constr~ints".

This wording should be revised and those responsible for making or assisting in the PAR decisionmakihg process should be trained on how to use the revised PAR chart. *This was considered as an Inspector Followup Item (No. 255/92019-02).

For the most part, communications.in the EDF and between other facilities and offsite organizations was adequate; however, there were four communications problems noted:

(1)

(2)

The EOF wa~ notified that a General Emergency (GE) had been declared at 1017 hours0.0118 days <br />0.283 hours <br />0.00168 weeks <br />3.869685e-4 months <br /> and that information was put on a status board; however, the EDF Di rector and EO were not immediately aware of.this. They found out that the GE was declared through conversations with state personne Most technical information from the TSC was adequately communicated to _the EOF; however, there were several occasions where it appeared-that the TSC had khown valuable or critical information and had not passed it on to the EO For example, the EOF did not know until well after the fact

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that an auxiliary pressurizer spray system valve had fa i1 ed close There was some confusion about what protective action recommendations (PARs) were given to the state and the

~ctions that.the stat~ had implemented~ The EO had to call the state on s~veral occasions to find out what the PAR status wa Direct radio communications with the offsite field teams did not work, nor was communicatio~ ~ith the backup cellular phone adequat Because of. this, the DSC had to maintain contact with the offsite teams ~nd give them directions from the EDF and transfer data back to the ED This delayed

. some dose assessment effort *

No violations or deviati-0ns were observe e.,

Field Monitoring Teams Field monitoring teams were not ~irectly observed during this exercis It was noted that there were considerable radio communications

~roblems with offsite*field monito~ing team The licensee was aware of this problem prior to the exercise, as documented in Deviation Report PAL-92-218, dated August.(, 199 The radio system manufacturer (Motorola) had been contacted, and-evaluated the performance of the system as acceptabl Contact with the Federal Communications Commission iridicated that there was anothe utility whose transmissions could_ be causing radio interferenc Alternate frequencie~ in the 450-451 MHz bahd are being ~onsidered and will be test~d.to determine.if they are acceptabl No violations or deviations were observe.

RecoverY Following the exercise, a tabletop demonstration of initial actions which would be taken during the Recovery* phase of an accident wefe demonstrate This included the selection of primary and alternate personnel to fill positions in the Recovery organization and the listing of initial considerations, immediate actions to be taken, and items needed to be considered in subsequent plannin The Recovery procedure was modified since the last exercise and now covers the ~xpected needs of the NRC as well as other consideration Initial Recovery discussions w~re considered excellen No violations or deviations were observe.

Exercise Objectives and Scenario Review (IP 82302)

The licensee submitted the exercise.and scope and objectives and a draft scenario package for review by the NRC within the established timeframe Scenario review did not indicate ~ny sign~ficant problems,

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and the licensee adequately responded to the questions raised during the scenario revie The scenario package was adequate in scope and content t6 ensure ease of use and contained enough information so that licensee controllers could control the exercis Backup information was

• available in the event that the plant simulator, utilized to "drive" the exercise; faile *

The licensee's scenafio was sufficiently challenging for a full participation exercise, including a large offsite release of radioactive materials, multiple eq~ipment failures, and assembly/accountabilit The degree of challenge in an exercise scenario is conside~ed when assessing observed exercise weaknesse No.violations or deviations were observed; Exercise Control Overall, exercise control was considered adequat There were adequate controllers to control the exercise, and they were knowledgeable regarding their task No in~tances of unrequired controller prompting were observe No violations or deviations were observed.

. 10. * Licensee Critiques The licensee held a Cbntrtiller exercise critique, and a critique where*

the Controller/Evaluators presented th~ir findings to the player NRC personnel attended sbme of these critiques, and determined that

. significant NRC identified* exercise deficiencies had also been identified by licensee personne.

Inspector Followup Items Inspector Followup Items are matters which have been discussed with the licensee which will be reviewed further by an NRC inspector and wh.ich involves some actions on the part of the NRC or licensee or bot ~n Inspector Followup Item disclosed du~in~ this inspection is discussed in*

Paragraph 6.d of this repor.

Exit Interview (IP 30703)

The inspectors held an exit interview on September 3, 1992, with the representatives denoted in Section The NRC Team Leader discussed the scope and findings of the inspectio The licensee was also asked if any of the information discussed during the exit interview was*

proprietary.. The licensee responded that none of the information was proprietar Attachments: Palisades 1992 Exercise Scope and Objectives

_ Palisades 1992 Exercise Scenar1o Outline

PALEX-92 SCOPE AND OBJECTIVES PALEX-92 is designed to meet exercise requirements specified in 10 CPR 50, Appendix E,Section IV.F. It will postulate events which would require activation of major portions of the

• Site Emergency Plan and response by State and local governments. The exercise will include participation by Allegan County, Berrien County, Van Buren County and the State of Michigan. The State of Michigan will demonstrate ingestion pathway planning for the Federal Emergency Management Agency. The Joint Public Information Center will be activated during the exercis OBJECTIVES The following objectives will be demonstrated as dictated by the exercise scenari.

Assessment and Classification Assess conditions which warrant classification within fifteen minutes of being provided those condition Classify posed conditions in accordance with Emergency Action Levels withiri

• fifteen minutes of determination that conditions warrant classification:. Communications Upon making an emergency classification, complete initial notifications within fifteen minutes to the State and locals and within one hour to the NRC using the *

Notifieation form..

• Complete subsequent notifications to the State, locals, and NRC on a routine fifteen minute basis or as mutually agree Contact other organizations such as contractors, utilities, fire or medical support within one hour of recognizing that conditions exist that warrant their assistance;

- Provide accurate press release information on plant conditions within one hour after occurrenc Provide updates between appropriate Emergency Response Facilities at least every 30 minute * Radiological Assessment and Control Collect, analyze, document and trend radiological survey dat Analyze plant radiological conditions and implement protective actions for site personnel in accordance with procedure 'Prepare and brief personnel for activities required in high radiation area Monitor, track and document radiation exposure to maintenance, operations, and monitoring team personne Calculate dose projections based on sample results or monitor reading Identify appropriate protective action recommendation Perform environmental monitoring in accordance with procedures and as directed by the Controlle.

Emergency Response Facilities Staff and activate onsite Emergency Response Facilities within approximately 30 minutes of an Alert classificatio b.. Staff and activate the Emergency Operations,facility within about an hour of the Site Area Emergency declaratio c.. Update status boards at least every 30 minute Document field team activities in logs and on appropriate status board Track and prioritize status of key in plant job.

Direction and Control Command and control all Emergency Resp0nse Facilities i~ accordance with.

assigned function Coordinate maintenance activitie Take appropriate measures to secure emergency equipment, supplies, and suppor Dispatch field. teams in accordance with procedure~. *Direct and monitor field team action Transfer Command and control in accordance with the Site Emergency Pla Perform accountability within approximately 30 minutes of the Alert classificatio i~*-.. *. Control site access and site evacuatipn as directe Brief Emergency Response Facility staffs approximately every 30 miriutes on changes in plant status, emergency classification, field team progress, and offaite actions as appropriat Effectively coordinate with State and local governments as appropriat k. * Demonstrate reentry and recovery in accordance with procedure.

Exercise Control Allow adequate free play for players to demonstrate their capabilitie Accurately assess performance of exercise players.and controller ~--~~ENARIO SUMMARY:

PALEX-92 is a Steam Generator Tube Rupture event with coincident loss of startup powe It loosely follows the analysis described by the FSAR, Section 14.15 and includes additional complications suggested by the Ginna Steam 'Generator Tube Rupture event of January 25, 198 The Control Room simulator will be used, and to. the extent possible, will be run in real time mode. Data sheets have been prepared and will be used if neede SEQUENCE OF EVENTS:

-0030/0800 Initial conditions are provided to Players:

The reactor is operating at full power at the end of core lif Equipment degraded/out of service:

Radwaste Evaporators M-59A and M-59B Limited radwaste storage capacity

. Miscellaneous Waste Transfer Pump P-92A

• Letdown* flow indicator FIC-Oi02 Containment Sump Level Indicator LIA-0359

. Alarms:

Annunciator EK-11-60, "Radwaste Panel C-105 off-normal" Annunciator EK-13-68, "Radwaste Panel C-40 off-normal" Annunciator EK-07-71, "Volume Control Radiation Monitor High Radiation" PCS leak rate (most recent results): 0.08 gpm identified, 0.044 gpm unidentified, 0.124 gpm tota Estimated primary to secondary leak rate: 0.001 gp /0830 The exercise begins with receipt of PCS activity sample results indicating a small amount of failed fuel. An ALERT should be declared*.

0030/0900 Site Emergency Plan activation complete. A small seal leak develops on CRD-17. A Service Water leak in Containment develops on Containment Air Cooler VHX-3. Progressive fuel rod failures commenc PCS activity* levels greater than permitted by Technical Specifications (confirmed by sample).

0130/100 A. double-ended rupture of a single tube in Steam Generator E-50B occurs, *

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resulting in Reactor trip and loss of Startup powe /1005 GENERAL EMERGENCY should be declare /1015 Operators commence cooldown, resulting in first release at low ~/G 'B, activity levels. Auxiliary Spray CV-2117 fail /1055 The ability to drain SIG 'B, to radwaste is los The second release at high S/G. 'B' activity levels* commence /1255 (Estimated)

Time jump conditions are provided to players; recovery planning* begin Players not involved in recovery planning begin critique /1500 Recovery planning is completed; the exercise is terminate.*i* NARRATIVE SUMMARY:

... 0800 (-0030) Tbe plant is at full power at the end of core life (11.1 GWD/Mru). No Technical Specification surveillance activities are in progres The plant will commence coast down shortly, with shutdown for refueling outage scheduled for next weekend. Based on current PCS activity trends, Reactor Engineering anticipates findirig approximately 5 leaking fuel a5semblies during the refueling (all burnt assemblies are to be inspected during the shuffle). Operators are unaware that various additional fuel rods within a single.reload "L" fuel bundle are in the process of failing due to vibration-induced mechanical

. frettin Plant radwaste capability is extremely taxed. Both radwaste evaporators and the VRS are currently out of service, and just enough clean waste holdup capaciiy is available to support operation to the weekend and subsequent shutdown and boratio * Management expectations as con_veyed to operat~rs are that, due to high system *

demand created by the unseasonably early _warm spring weather, every attempt

. consistent with safe plant operation shall be made to adhere to the scheduled

• weekend shutdown and that no testing or evolutions which have the potential to jeopardize this goal are to be authoriZed (the reason for this admonition is that an attempt to perform turbine valve testing the previous weekend to check out new DEH controls had resulted in an unanticipated derate to 60% ).

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• F. * *Equipment in a degraded mode:

1. * Radwaste Evaporator M-59A has been out of service for one month due to

. non-availability of obsolete part. Radwaste Evaporator M-59B is out of service to replace "rocked up" recirculation pump discharge line. The Volume Reduction System is out of service while repairs are made to the

• extrude. Miscellaneous Waste Transfer Pump P-92A is tagged out for pump rebuild and motor replacement and is completely disassemble. Letdown Flow Indicator FIC-0202, while in service, is out of calibration and reads approximately 5 gpm too low. A work request has been submitte. Containment Sump Level Indicator LIA-0359 is out of service due to failed meter movement. A replacement meter is on order. (This malfunction is necessary due to simulator modeling limitations.)

• G. * Rad waste Systems tank status:

• Clean Waste System:

T-64A CWRT Level 95%

T-64B CWRT Level 95%

T-64C CWRT Level 56%

T-64D CWRT Level 0%

T-96 RBAT Level 10% 15,200ppm Existing Alarm Conditions:

Dirty Waste System:

T-92A Misc Waste Tk Level 97%

T-92B Misc Waste Tk Level 98 %

T-92C Misc Waste Tk Level 75%

T-94A Clean Cone Tk.Level 98%

T-94B Clean Cone TkLevel 97%

T-95A Dirty Cone Tk Level 97 %

T-95B *Dirty Cone Tk Level 98 %

1. Annunciator EK-11-60, "Radwaste Panel C-105 off~normal"

• 2. Annunciator EK-13-68, "Radwaste PanelC-40 off-normal" 3. Annunciator EK-07-71, "Volume Control Radiation Monitor High Radiation" has just been received. Chemistry has been directed to sample the PCS for activity and is in the process of obtaining the sampl Meteorological Conditions are as follows:

1. Unusually warm and dry spring conditions exist, with sustained winds from the southwes a. Wirid Speed: 2-4 mph *

b. Wind Direction: 225. degrees c. Stability: DIE d. Ambient Temperature: 80-90 degrees Fahrenheit Primary and Secondary Chemistry *

1. Primary System Chemistry (prior to sample in progress)

a. pH: 7.07 b. Boron: 5 ppm

c. Dissolved Oxygen: less than 0.002 ppm d. Hydrogen: 25 cc/kg e. Total_ Beta Gamma Activity: 2.04 pCilml f.. Iodine Do~ Equivalent: 0.053 pCi/ml g. Total PCS Gas Activity: 15.2 )lCi/ml h. PCS Xe-133 Specific Isotope Activity:. 40.0 µCi/ml 2. Secondary System Chemistry *

a. Primary toSecondary Leak Rate:

0~001 gpm b. Offgas Xe-133: 5.42E-6 pCi/ml c. Condenser Air In-leakage: 1 scfm d. A and B Steam Generator Gross Gamma Activities: Less than 5.6E-6

µCi/ml PCS Leak Rate (most recent results)

1. Identified: 0.08 gpm *

2. Unidentified: 0.044 gpm 3. Total: 0.124 gpm 0830 - 0900 (0000 - 0030) The exercise begins with the hot lab Chemistry Technician reporting initial PCS activity results of 30 µCi/gm Iodine dose equivalent 1-131. Subsequent backup samples will yield similar results, ie, results that permit continued operation for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> under the LCO of Technical Specifications 3.1.4.b and c (which are designed to accommodate possible Iodine spiking phenomenon resulting from thermal power excursions such as the previous weekend). Expected Actions:

1. Conclude that fuel damage may be indicated and refer to ONP-11.1, "Fuel Cladding Failure" and Emergency Plan Implementing Procedure EI-. The Shift Supervisor will assume the Site Emergency Director (SED) position.

and:

a. Classify an "ALERT" based on "Primary Coolant Iodine-131 Dose Equivalent Concentration greater than 25 µCi/gm."

b. Directs a public address announcement on the situation and sounding of the emergency sire c. Delegates actions and notifications identified in EI-1 and marked on EI-.

2.1 Attachment 1, including emergency staff augmentation; personnel accountability; activation of the Operational Support Center (OSC) an Technical Support Center (fSC); dose assessment; and activation of the Emergency Response Data System (EROS).

• *d.. Directs completion of the emergency notification forms of EI-3 and NOD Form)16 e. Commences 15 minute notifications per EI-. The PCS Sample requirements for isotopic Iodine analysis of Technical Specification Table 4.2.1 will be invoke (0030 - 0100) Activation of the Site Emergency Plan continue "Rod Drive Seal Leakoff High Temperature" Alarm is received (EK-09-54) due to a small (approximately 0.1 gpm) increase in seal leakage on CRD-1 "Containment Sump High Level" Alarm is received (EK-13-51) due to a Service Water leak of approximately 15 gpm which has developed on Containment Air Cooler VHX-3. (NOTE: Due to simulator modeling limitations, indicated Containment Sump Level will ramp to 10% and remain there for the duration of the exercise, rather than respond as expected to attempts to drain the sump.) Progressive fuel rod failures in the affected Reload "L" fuel bundle commenc Expected Actions:

1. Complete staffing of the OSC, MSC and TSC and turnover responsibilit. Continue PCS activity samples via NSSS sample system while considering implementation of EI-7.0, Emergency Post-Accident Sampling Deci~ion Proces. Alarm Response Procedures will force players to consider the possibility of a

, PCS leak, although the two alarming conditions (Rod Drive Seal Leakoff High Temperature and Containment Sump High Level) are actually unrelated. **

No other oorresponding symptoms are present, and it would be appropriate to consider a Containment entry, although containment conditions are somewhat suspect. Also, performance of a quick (one hour) PCS leak rate calculation would be prudent (if performed, an increase of approximately 0.1 gpm due to the leaking CRD-17 seal would be indicated).

4. Players will attempt to obtain a sample of Containment Sump contents to assist in determining leakage source. If successful, high sodium will be

. indicated, symptomatic of a Service Water lea. Players will recognize that the Contain_ment Sump leakage represents a new dirty radwaste source (greater than 21,000 gallons/day) that will quickly expend remaining dirty waste storage capacity and will attempt to identify*

alternate storage options and maintenance activities to increase radwaste processing capability (eg, expedite _repairs to "B" evaporator).

6. Repairs will he expedited to Letdown Flow Indicator FIC-020 (0100 - 0115). JPIC is operationa PCS activity levels increase as the Reload "L" fuel bundle rods fai C. * Players make preparations to transfer radwaste to alternate storage locations using available equipment and temporary modifications as necessary. Meanwhile, dirty radwaste activity levels continue tq increase due to CRD seal leakage to the Containment Sump and NSSS sampling activitie D.. Control Room personnel continue activities to identify and quantify the containment water sourc Expected Actions:

1. Players will identify adequate radwaste storage capacity to accommodate dirty waste and permit continued operation. *Acceptable options include:

a. Treate.d Waste Monitor Tanks T-66A and T-66B (10,800 gallons capacity).

b. Filtere.d Waste Monitor Tanks T-63A and T-63B (5,400 gallons capacity).

..

c. Laundry Drain Tanks T-70A and T-70B (1,100 gallons capacity).

d. Temporary modifications, valve lineups and procedures are required for all options identifie.

.

2. The containment water source will be identified as service water and the LCO of Technical Specification 3.4.2 will be e.ntere. 3. Players will not elect to retain water in the Containment Sump due to negative implications for various accident analyses..

4. Players may decide that they cannot support continued operation an4 commence plant shutdown. This is permissible, although unnecessary at this point,.but if undertaken it must be controlled to as slow a rate as possible ("to minimize fuel effec.tS") since scenario data sheets will not reflect the shutdown until 0945 (0115).

0945 - 1000 (0115 - 0130) The latest PCS activity sample indicates 50 µCi/gm loditw dose equivalent 1-13 This is confirmed by a second sampl Expected Actions:

1. Commence plant shutdown to conform to Technical Specification 3. I. (OI30 - OI37)

A.. A double-ended rupture of a single tube in Steam Generator E-50B occurs, resulting in a primary to secondary leak which. exceeds the capacity of the Charging Pump * Operators trip the Reactor, or an automatic trip on Thermal Margin/Low Pressure occur C.. Two seconds after the Turbine Generator trips and busses IA and lB fast transfer to Startup Transformers 1-1 and 1-3, respectively, the 'R' Bus trips due to failed sudden pressure relay 486X-11 on Startup Transformer I-1, deenergizing Busses IA and lB arid supplied loads (Primary Coolant Pumps and Condensate Pumps). An Iodine spike generated by the trip (spiking factor = 500) occur Auxiiiary Feedwater Automatic Actuation occurs due to low level in the 'A'

Steam Generator and commences feeding both S/G' Five minutes after the trip, Safety Injection is automatically initiated at 1605 psia. Flow to the PCS begins approximately fourteen minutes after the tri Expected Actions:

1. * EQP-1.0 standard post-trip actions will be commence. A GENERAL EMERGENCY will be declared due to loss of all three fission product barriers, as all Atmospheric Dump Valves automatically open on the trip for core heat removal.

. 1007 - 1015 (0137 - 0145) EOP-1.0 standard post-trip actions are complete The Pressurizer; which had emptied shortly after the trip~ begins to refi,11 from Safety Injection flo Expected Actions:

1. The EOF will be declared operational and assume responsibilities for Protective Action Recommendation. EOP-5.0, "Steam. Generator Tube Rupture" will be invoked (EOP-9.0,

. "Functional Recovery Procedure" is also acceptable, althou~h unnecessary).

1015 - 1055 (0145 - 0225)

A. * Operators implement EOP-5.0 actions and, since no Primary Coolant Pumps are operating and the Turbine Bypass valve is disabled by low c0ndenser vacuum, commence steaming both Steam Generators via the Atmospheric Dump Valves to provide uniform PCS cooling. This* creates a direct re'lease path via 'B' Steam Generator Atmospheric Dump Valve B.. The faulted Steam Generator is readily recognized as E-50B, but isolation is not permitted until the PCS is cooled below. 525 degrees Fahrenheit as forced circulation does not exis Since PCP's are not is service, PCS depressurization is attempted using Charging Pumps and Auxiliary Spray CV-2117; however, CV-2117 is failed in the closed position due to a burned up solenoid (position indication is still operable). This will hamper pressure reduction and place reliance on Safety Injection throttling to minimize the dip across the failed SIG 'B' tube, which will not be effective in preventing the SIG from filling solid and challenging the code safetie.-. Expected Actions:

1. Operators will terminate Auxiliary Feedwater to SIG 'B' (it will continue to fill via the Failed Tube).

2. The PCS will be cooled below 525 degrees fahrenheit using Atmospheric Dump Valves and Auxiliary Feedwater to SIG *A' and SIG 'B' Will be

_isolated. The release via the SIG 'B' Atmospheric Dump Valves will thus cease for the presen. Protective Action Recommendations will be made to the State recommending evacuation of affected sectors in Van Buren and_ Allegan_

countie (0225 - 0315)

A~ 'B' Steam Generator, although isolated, continues to fill rapidly via the ruptured tube due to the_ high primary-to-secondary dP created by the inability to -

adequately reduce.PCS pressure (Note: The fill rate will be artificially adjusted on the simulator such that the 'B' SIG and connecting steam piping will fill solid in one hour.) Operators continue to cool down as rapidly as possible under natural circulation conditions using the unaffected_ 'A' Steam Generator_ (approximately 50 degrees-Fahrenheit/hr). Expected Actions:

1. Operators will attempt to combat the rapidly increasing SIG '.B' level by transferring Mjscellaneous Waste Hold Tank contents to a Clean Waste Receiver Tank to make room to drain SIG 'B' to Miscellaneous Waste (requires jumpering by I&C of SIG Blowdown Monitor RIA-0707); however, this attempt will result in the remaining Miscellaneous Wa.Ste Transfer Pump, P-92B, failing due to motor overheating. Alternate_drain paths will not be identifie. Area surveys will identify affected plant sectors, and access will be restricted/ controlled as appropriat. - Operators may attempt to regain forced circulation by backfeeding the Main Transformer; this option will not be permitted until after 1145 (0315) to hamper PCS pressure reduction efforts. (Also, the simulator does not currently model backfeed.)

-

..

1145 - 1245 (est) (0315 - 0415) (est) 'B' Steam Generator level is greater than 100% and is*filling the connecting Main Steam pipin * 'B' SIG contents are now highly radioactive with PCS fission product Players are faced with two choices:

1. Permit steam piping to fill solid and hope for the bes. Steam-SIG.. 'B'- to cool it and reduce its level to prevent challenging Main

• .Steam safetie Election of either option of C above will result in a release to the atmosphere (if players permit steam piping to fill solid, either a code *safety will open and fail open or an overstressed piping section wiil yield and fail, depending on how successful players have been at reducing 'B' SIG pressure previously). Expected Actions:

1. Players will elect to Steam 'B' Steam Generator as necessary to maintain

• level indication on scale until such a time as 'B' SIG pressure is below safety valve setpoints and then permit steam piping to fill solid; This action permits planned releases that can be coordinated with evacuation and other Protective Action Recommendations and off site monitoring efforts..

2. Proteetive Action-Recommendations will be revised as appropriat.. The release of this phaSe of the exerdse may be continued a5 long as necessary to demonstrate exercise objective _ (est) - 1500 (0415 (est) - 0630) Players are provided new plant conditions. Personnel not involved in recovery planning terminate participation and conduct critique * B. *Approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> have elapsed from the time of the plant trip. Forced circulation has been regained by ~ackf eeding the Main Transformer and restarting PCP's P-50B and P-50C. Shutdown Cooling is in service, the Pressurizer is filled solid, and PCS cooldown is in progress at 40 degrees fahrenheit/h 'B' Steam Generator is re-isolated (o~ steaming to atmosphere slowly if the piping break option was necessary) zjld is filled soli..

D.. Expected Actions:

1. Implement plans for reentry/recovery..

2. Continue to cool down at the maximum permitted rat. Implement appropriate radiological controls for both primary and se.condary systems high fission product content. Consider options to minimize release from the steam line break (if the piping break option was necessary), eg, temporary barriers/enclosure + (0630 +)

Terminate exercise.